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OECD's guidance on transfer pricing implications of COVID-19: nothing “new” in the “new normal” The IMF's Annual Report for 2020 described the COVID-19 pandemic as a "crisis like no other", which has "created the worst recession since the Great Depression". The health emergency has forced many economies to a standstill. While some businesses, such...
DAC6: over (in the UK) before it’s begun? The UK has effectively repealed DAC6 for the majority of cases. With effect from 11 pm (UK time) on 31 December 2020 – the day before DAC6 reporting was due to begin in earnest - the UK implementing regulations have been amended to disapply DAC6 in...
EPO study reveals UK and European positions in global 4IR patent race What do you know of Industry 4.0, or the Fourth Industrial Revolution (4IR)? Characterised by the growing utilisation of emerging technologies such as artificial intelligence (AI), cloud computing, robotics, 3D printing, the Internet of Things and...
And finally, "everything" is agreed Boris Johnson and Ursula van der Leyen announced this afternoon that the UK and the EU have reached agreement on the text of a trade deal.  The ratification process is now to be fast-tracked, with a view to bringing the agreement into force by 11pm on New...
EUIPO report on online copyright infringement of film, TV and music – so what’s popular? It’s amazing what a difference 12 months makes.  Back in 2019,  a EUIPO study found that  online copyright infringement in the EU between 2017 and 2018 was a declining but significant problem (namely access to pirated content fell by an average of 15.1%)....
Ushering in a new age of accountability for big tech- UK government response to Online Harms White Paper consultation The UK government has taken the next step in its plan to “usher in a new age of accountability for tech companies”, publishing the response to its consultation on the Online Harms White Paper. It has committed to making the Online Safety Bill, which will...
NIS 2 - new cyber rules would mean more critical sectors covered and enhanced security requirements The NIS regime, which aims to boost the overall level of cyber security in the EU by improving the security of network and information systems across critical sectors, has been under review at both EU and UK level. On 16 December 2020, the European...
Corporate tax residence: latest from the Court of Appeal In the latest instalment of the Development Securities litigation, the Court of Appeal unanimously overturned the Upper Tribunal (UT) decision, reinstating that of the First-tier Tribunal (FTT).  This is a difficult case, as not only has the decision been...
FireEye of the storm for cyber risk? On Tuesday the PRA sent a letter to UK insurance CEOs, in which it explained its supervisory priorities for 2021. Unsurprisingly, financial resilience remains at the top of the list. Equally it's unsurprising to see operational resilience included as a...
Dutch Supreme Court rules on applicability of participation exemption in the context of uncovered call options and benefits from German cum/ex trades Recently, the highest court in the Netherlands ruled that (a) uncovered call options cannot be regarded as a participation, and (b) benefits derived from German cum/ex trades cannot be regarded as originating from a participation. Market Maker's trades...